Ampyx Cyber Blog

The Intersection of Regulation & Resilience

CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12
Deep Dive Patrick Miller Deep Dive Patrick Miller

CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12

Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.

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CIP-015-1 INSM: A Practical Playbook
Deep Dive Patrick Miller Deep Dive Patrick Miller

CIP-015-1 INSM: A Practical Playbook

NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.

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Help Shape the Future of the NERC CIP Standards
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Help Shape the Future of the NERC CIP Standards

NERC is asking for industry input on the future of CIP Standards. As part of its 2025 Work Plan, NERC has launched a survey to identify and prioritize emerging security risks to the Bulk Power System. The results will directly inform a roadmap for updating the CIP Standards to address today’s evolving threat landscape. What’s happening, why it matters, and how you can participate before the July 22 deadline.

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FERC Quietly Closes The Books on RM20-12-000
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Quietly Closes The Books on RM20-12-000

FERC has officially closed Docket RM20-12-000, ending a five-year inquiry into potential gaps in the CIP Reliability Standards. While the docket is withdrawn, the underlying concerns—data security, anomaly detection, and coordinated cyberattacks—are being addressed through recent standards like CIP-015-1 (INSM) and proposed updates to CIP-003.

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FERC Finalizes INSM Standard: CIP-015-1 and the New Visibility Mandate for the Grid
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Finalizes INSM Standard: CIP-015-1 and the New Visibility Mandate for the Grid

On June 26, the Federal Energy Regulatory Commission issued Order No. 907, approving the new NERC Reliability Standard CIP-015-1: Cyber Security – Internal Network Security Monitoring (INSM). This marks a critical shift in how we approach cybersecurity within the Bulk Electric System. It also raises the bar significantly on what’s expected for visibility inside the network perimeter.

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NERC CIP-002 Standards Authorization Request - Project 2021-03
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

NERC CIP-002 Standards Authorization Request - Project 2021-03

NERC’s CIP-002 Project 2021-03 (Phase 2) introduces key updates to improve clarity and consistency in identifying and classifying BES Cyber Systems. The revisions address long-standing ambiguities by clarifying functional entity roles, refining the treatment of communication protocol converters, revising Criterion 1.3 to establish objective criteria for high-impact control centers, and expanding Criterion 2.6 to include control centers operated by Generator Operators and Transmission Owners. These changes aim to eliminate gaps in protection, align risk-based categorizations across all entities, and support more consistent compliance with CIP standards.

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Four Years In: What NERC’s Cyber Security Incident Reporting Data Tells Us (and What It Doesn’t)
Deep Dive Patrick Miller Deep Dive Patrick Miller

Four Years In: What NERC’s Cyber Security Incident Reporting Data Tells Us (and What It Doesn’t)

In the world of Bulk Electric System (BES) cybersecurity, signals of risk don’t always arrive with alarms blaring or malware lighting up dashboards. Sometimes, the signs are quieter—brute force login failures, odd port scans, or a sudden spike in account lockouts. The annual CIP-008-6 report, filed March 21, 2025 by NERC, shines a small but telling light on just such signals.

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FERC Proposes New Standards for INSM: Internal Network Security Monitoring (CIP-015-1)
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Proposes New Standards for INSM: Internal Network Security Monitoring (CIP-015-1)

The Federal Energy Regulatory Commission (FERC) has issued a new Notice of Proposed Rulemaking (NOPR) under Docket No. RM24-7-000. This proposed rule seeks to approve NERC’s proposed Critical Infrastructure Protection (CIP) Reliability Standard CIP-015-1. The new standard focuses on Internal Network Security Monitoring (INSM) to detect and address cyber threats within the electronic security perimeter of the Bulk Electric System (BES).

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FERC’s New Proposed Rule on Supply Chain Risk Management (SCRM)
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC’s New Proposed Rule on Supply Chain Risk Management (SCRM)

The Federal Energy Regulatory Commission (FERC) has released a new Notice of Proposed Rulemaking (NOPR) under Docket No. RM24-4-000, focusing on supply chain risk management (SCRM) for the Bulk-Power System (BPS). This proposed directive aims to fill critical gaps in existing NERC Critical Infrastructure Protection (CIP) standards and bolster the defenses of our nation’s critical infrastructure.

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FERC Staff Report Offers Lessons Learned from 2024 CIP Audits: What You Need to Know
Deep Dive Patrick Miller Deep Dive Patrick Miller

FERC Staff Report Offers Lessons Learned from 2024 CIP Audits: What You Need to Know

In its 2024 CIP audit report, the Federal Energy Regulatory Commission (FERC) shared critical lessons learned from the latest round of reliability audits, revealing key areas where NERC-registered entities can strengthen their security posture. While many organizations successfully met compliance requirements, the report highlighted specific gaps in asset categorization, control center segmentation, and data protection that could pose significant operational risks.

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Embracing AI for the Electric Grid: Insights from NERC
Patrick Miller Patrick Miller

Embracing AI for the Electric Grid: Insights from NERC

In the rapidly evolving landscape of the electric sector, the integration of cutting-edge technologies is not just an option; it's a necessity. Among these, artificial intelligence (AI) stands out as a transformative force, offering unprecedented opportunities to enhance grid reliability, security, and efficiency. Recognizing this potential, the North American Electric Reliability Corporation (NERC) has provided insightful comments on how AI can be harnessed to address the challenges and opportunities within the electric grid.

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CIP-015: The Crucial Role of INSM in Strengthening Grid Security
INSM Patrick Miller INSM Patrick Miller

CIP-015: The Crucial Role of INSM in Strengthening Grid Security

introduction of CIP-015, a new regulation aimed at enhancing grid security by mandating Internal Network Security Monitoring (INSM) for high and medium impact Bulk Electric System (BES) Cyber Systems. This development, initiated by FERC Order No. 887, responds to the need for robust monitoring within trusted network zones to detect and mitigate potential cyber threats. CIP-015 emerges as a standalone standard after industry feedback suggested that INSM requirements did not align well with existing frameworks, shifting towards an objective-based rather than prescriptive approach.

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NERC's New INSM Regulation: Assessing Impact and Ambiguity
INSM Patrick Miller INSM Patrick Miller

NERC's New INSM Regulation: Assessing Impact and Ambiguity

The recent draft release of NERC's new CIP Standard for Internal Network Security Monitoring (INSM) sparks a conversation filled with anticipation and skepticism. With directives from FERC Order 887 echoing in its language, the draft attempts to navigate through the challenges of creating a new regulation to address situations where vendors or individuals with authorized access are considered secure and trustworthy but could still introduce a cybersecurity risk.

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Embracing the Cloud: A New Era for BES Operations
Cloud Patrick Miller Cloud Patrick Miller

Embracing the Cloud: A New Era for BES Operations

This insightful blog post delves into the critical aspects of cloud migration, offering a strategic roadmap for businesses. It emphasizes the importance of a well-thought-out plan, highlighting the need for compatibility assessment, data security, and cost management. The article also stresses the significance of choosing the right cloud provider and preparing the workforce through training and support. This guide is an essential resource for organizations seeking to navigate the complexities of transitioning to cloud computing, ensuring a seamless and successful migration.

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Understanding NERC's CIP-004-7 and CIP-011-3: A Deep Dive into BCSI Access, Cloud Challenges, and Encryption
BCSI Patrick Miller BCSI Patrick Miller

Understanding NERC's CIP-004-7 and CIP-011-3: A Deep Dive into BCSI Access, Cloud Challenges, and Encryption

Stay ahead of the curve with a comprehensive overview of NERC's new Critical Infrastructure Protection (CIP) standards, CIP-004-7 and CIP-011-3, set to be effective from January 1st, 2024. Understand the pivotal changes concerning BES Cyber System Information (BCSI) access, the nuances of cloud BCSI, and the strategic choices around encryption.

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Inverter-Based Resources - Guide to Potential NERC CIP Impacts of Upcoming Regulatory Changes
IBR Patrick Miller IBR Patrick Miller

Inverter-Based Resources - Guide to Potential NERC CIP Impacts of Upcoming Regulatory Changes

Upcoming NERC regulatory changes are expected to result in a significant increase in registrations of inverter-based resources, resulting in the likelihood of control centers to be categorized as North American Electrical Reliability Corporation (NERC) Critical Infrastructure Protection (CIP) Medium-Impact Control Centers and/or Low-Impact Control Centers and correspondingly to meet the relevant NERC CIP requirements.

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NERC Initiates Data Collection on INSM for Low Impact CIP Assets
INSM Patrick Miller INSM Patrick Miller

NERC Initiates Data Collection on INSM for Low Impact CIP Assets

NERC has initiated the Internal Network Security Monitoring (INSM) Data Request in response to a directive from FERC. This effort aims to gather data on the risks of not implementing INSM in medium and low impact BES Cyber Systems. NERC is collecting information from utilities in the electric power industry regarding facility numbers, network configurations, malicious code detection, implementation challenges, and alternative solutions. The data must be submitted by July 25, 2023.

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New cybersecurity controls for vendor access to low impact NERC CIP assets
NERC CIP Patrick Miller NERC CIP Patrick Miller

New cybersecurity controls for vendor access to low impact NERC CIP assets

FERC has approved new cybersecurity standards to improve risk management practices and supply chain risk management for low impact assets. The new standards, designated CIP-003-9, require utilities to establish and maintain a documented supply chain cyber risk management plan and implement vendor-focused cybersecurity protections for their low impact BES Cyber Systems.

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